Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

Lovely, Graham

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Master thesis . 2011

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Master thesis . 2015

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Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

descriptionPublicationkeyboard_double_arrow_right Master thesis 01 Jan 2011 South Africa English Publisher:Department of Commercial Law

Authors: Lovely, Graham;

handle: 11427/11135

Does the proposed dividends tax overcome the international tax flaws that secondary tax on companies may have, namely exclusion from the scope of some double tax agreements and violation of the anti-discrimination provisions embodied in the OECD mode

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Abstract

Secondary tax on companies (STC) and the new dividends tax and its exemptions therefrom could be in contravention of the non-discrimination provisions of Article 24(5) of the OECD MTC. This question has not been decided in a South African court. This dissertation proposes the resolution to this question. The outcome of this research may be particularly relevant in the context of the proposed new dividends tax and value extraction tax (“VET”) and the exemptions therefrom, which are, again, based on residency.

Includes bibliographical references (leaves 54-55).

Country

South Africa

Related Organizations

University of Cape Town
South Africa

Keywords

Taxation

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